Systemic Risk and Deposit Insurance Premiums

8/7/2019 Systemic Risk and Deposit Insurance Premiums

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Systemic risk and deposit insurance premiums

Viral Acharya4 September 2009

Financial institutions enjoy a large number of government guarantees. This column says that we ought to becharging banks for such subsidies and doing so in a way that promotes financial stability. It uses the example ofdemand deposit insurance in the US to explore the poor design of funding for such guarantees.

We stand at interesting crossroads. Increased financial regulation is coming (Masciandaro and Quintyn 2009). Boldplans are being proposed for:

Resolving distress of systemically risky institutions, expanding the perimeter of regulation to hedge funds, setting standards for compensation structures, and enhancing transparency of derivatives and other off-balance-sheet activities.

Will these plans work?The answer will depend on the details of their execution, yet, one omission is striking even at the blueprint stage.There is little, if any, recognition that a large number of explicit guarantees (subsidies) still exist for the financialsector. These include most notably deposit insurance and temporary guarantees for debt issuance, and in somecases, explicitly for asset losses, offered to banks during the ongoing crisis.

Charging the financial sector for these guarantees in a manner that preserves financial stability ought to be on theregulatory agenda. But perhaps it is easier to design regulation than to measure and charge for its costs directcosts to taxpayers and indirect costs due to induced incentives for banks to take excessive risks. (This column islargely based on Acharya, Santos and Yorulmazer 2009.)So, here is an attempt to provide a 101 on how to charge for one such guarantee the government provision ofdemand deposit insurance to banks, and an assessment of the current scheme for charging of such insurance byone country, in particular, the US. Though our assessment of the US scheme is critical, it must be noted that it isone of the few countries to have in place an explicit deposit insurance fund and to make an attempt to charge risk-sensitive premiums. Many countries such as the UK had offered deposit insurance without the necessaryinstitutional arrangements for its delivery and pricing.

How to charge for deposit insurance

Banks are funded to a large extent by short-term liabilities called demand deposits that providers of depositschoose to roll over each day in the sense that they have the right to demand that their deposits be paid back at anypoint of time. Such demand deposits are explicitly or implicitly insured (up to some threshold per account orindividual) in most countries. While regulators in some countries have realised the need to set up a deposit

insurance fund only during the ongoing crisis, such funds are prevalent in most developed countries. Furthermore,during the financial crisis of 2007-2009, many countries, most notably Australia and New Zealand, introducedguarantees, whereas a significant majority increased their insurance coverage. The capital of deposit insurancefunds which will be needed in case an insured bank cannot meet its depositors demands is essentially thereserve built up over time through collection of insurance premiums from insured banks.It would seem natural that much thought must have gone into how such premiums should be charged. It is thusrather surprising that most countries funds have no insurance premium being charged and the few countries whosefunds do charge a premium (such as the US) do so in a manner that is not sufficiently risk-sensitive andunfortunately pro-cyclical, so that the funds are almost certain to be strapped for capital when insurance claimsmaterialise.

Three simple principles

Given the relatively vast quantity of deposit insurance offered globally to the banking sector without proper charging,we lay out three simple rules for how deposit insurance premium should be charged:

1. The premium should be sensitive to the risk of individual banks but also to systemic risk; that is, it shouldincrease not only in individual bank failure risk but crucially also in the joint bank failure risk.

2. The premium for large banks should be higher per unit insured deposit compared to small banks.3. The premium should be charged not just to be actuarially fair, that is, to ensure that the fund breaks even

on average, but also to discourage moral hazard associated with the insurance. In particular, todiscourage banks from herding and creating excessive systemic risk, the premium should charge moreforsystemic risk than what the actuarially-fair premium would.

Our first and most basic prescription is that the extent of systemic risk in the financial sector is a key determinant ofefficient deposit insurance premiums to be charged to insured banks. When a bank with insured deposits fails, thedeposit insurance fund takes over the bank and sells it as a going concern or piece-meal. During periods withwidespread bank failures, it is difficult to sell failed banks at attractive prices since other banks are also experiencingfinancial constraints (Shleifer and Vishny, 1992). Hence, in a systemic crisis, the deposit insurance fund suffers froma low recovery from liquidation of failed banks' assets. This, in turn, leads to higher drawdowns per insured deposit.Second, the failures of large banks lead to greater fire-sale discounts. This has the potential to generate a significantpecuniary externality that can have adverse contagion-style effects on other banks and the real economy (comparedto effects stemming from the failure of smaller banks). Hence, the resolution of big banks is more costly for thedeposit insurance regulator, directly in terms of losses from liquidating big banks and indirectly from contagion
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effects.And third, bank closure policies reflect a time-inconsistency problem (Mailath and Mester, 1994, Acharya andYorulmazer, 2007, 2008). In particular, the regulators would ex antelike to commit to be tough on banks when thereare wholesale failures to discourage them from ending up in that situation. However, this is not credible ex post regulators show greater forbearance during systemic crises. While such forbearance has featured in the ongoingcrisis from most regulators around the world, it has a strong set of precedents .1However, it is also true that suchforbearance is costly ex post, e.g. due to the fiscal costs of government intervention during crises. Such forbearanceduring systemic crisis creates a collective moral hazard whereby banks have incentives to herd and become inter-connected so that when they fail they fail with others and increase their chance of a bailout (see Acharya 2009 for afuller description).

Assessment of the deposit insurance premiums in the US

While our three principles to determine efficient deposit insurance premiums apply generally, it is useful to considerthem in the context of how premiums have been priced in the United States. To this end, we discuss the FederalDeposit Insurance Corporation (FDIC), the deposit insurance regulator, and the premium schemes that haveprevailed so far in the US (this discussion is largely based on Saunders and Cornett 2007, Pennacchi 2009 andCooley 2009).As a response to the devastating effects of the Great Depression, the FDIC was set up in 1933 to insure deposits ofcommercial banks and to prevent banking panics. The FDIC's reserves began with a $289 million capital injectionfrom the US Treasury and the Federal Reserve in 1934. Through most of the FDIC's history, the deposit insurancepremiums have been independent of the risk of banks, mostly due to the difficulty in assessing banks' risk. Duringthe period 1935-1990, the FDIC charged flat deposit insurance premiums at the rate of approximately 8.3 cents per$100 insured deposits. However, starting in 1950, some of the collected premiums started being rebated. Therebates have been adjusted to target the amount of FDIC reserves in its Deposit Insurance Fund (DIF).While the banking industry usually wanted deposit insurance assessments to be set at a relatively low level, theFDIC wanted premiums to be high enough that the reserves could cover future claims from bank failures. In 1980,the DIF was given a range of between 1.1% and 1.4% of total insured deposits. As a result of large number of bankfailures during the 1980s, the DIF was depleted and the Financial Institutions Reform, Recovery, and EnforcementAct of 1989 mandated that the premiums be set to achieve a Designated Reserve Ratio (DDR) of reserves to totalinsured deposits of 1.25%. Figure 1 shows the total insured deposits by the FDIC and Figure 2 shows the balancesof DIF and the reserve rat io for the period 1990-2008.Figure 1. Total deposits insured by FDIC

Source: FDIC.Figure 2. Balances of DIF and the reserve ratio
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Source: FDIC.The bank failures of the 1980s and early 1990s led to reforms in the supervision and regulation of banks such as theFederal Deposit Insurance Corporation Improvement Act in 1991 that introduced several non-discretionary rules. Inparticular, it required the FDIC to set risk-based premiums, where premiums differed depending on three levels of abank's capitalisation (well-, adequately- and under-capitalised) and three supervisory rating groups (rating 1 or 2,rating 3, and rating 4 or 5).However, the new rules have not been very effective in discriminating between banks and during 1996-2006, over90% of all banks were categorised in the lowest risk category (well-capitalised, rating 1 or 2). Further, the 1991legislation and the Deposit Insurance Act of 1996 specified that if DIF reserves exceed the DDR of 1.25%, the FDICis prohibited from charging any insurance premiums to banks in the lowest category. During the period 1996-2006,DIF reserves were above 1.25% of insured deposits and the majority of banks were classified in the lowest riskcategory and did not pay for deposit insurance.The Federal Deposit Insurance Reform Act of 2005 brought some changes to the setting of insurance premiums. Inparticular, instead of a hard target of 1.25%, the DDR was given the range of 1.15% to 1.50%. When DIF reservesexceed 1.50% (1.35%) 100% (50%) of the surplus would be rebated to banks. If DIF reserves fall below 1.15%, theFDIC must restore the fund and raise premiums to a level sufficient to return reserves to the DDR range within fiveyears.During the crisis of 2007-2009, the reserves of DIF have been hit hard. The reserves did fall to 1.01% of insureddeposits on June, 30, 2008, and they decreased by $15.7 billion (45%) to $18.9 billion in the fourth quarter of 2008,plunging the reserve ratio to 0.4% of insured deposits, its lowest level since 30 June 1993. Indeed at suchcapitalisation, even relatively small bank failures such as the Silverton Bank in Georgia, Bank United in Florida, and,most recently, the Colonial Bank in Alabama (with respectively around $4 billion, $12 billion and $27 billion inassets) threatened to wipe out the funds reserves unless ready buyers were found in the private sector. In the firstweek of March 2009, the FDIC announced that it planned to charge 20 cents for every $100 insured domesticdeposits to restore the DIF. On 5 March 2009, Sheila Bair, the FDIC chair, said the FDIC would lower the charge toaround 10 basis points if its borrowing authority were increased. Senators Dodd and Mike Crapo, introduced a billthat would permanently raise FDIC's borrowing authority to $100 billion, from $30 billion, and would also temporarilyallow the FDIC to borrow as much as $500 billion in consultation with the president and other regulators.

This discussion confirms our starting assertion that deposit insurance premiums have either been risk-insensitive orrelied only on individual bank failure risk and never on systemic risk. Further, even when premiums have been risk-


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sensitive, the focus has been on actuarially fair premiums. This is reflected in effectively returning the premiums tobanks when the deposit insurance fund's reserves become sufficiently high relative to the size of insured deposits.This kind of premium scheme is simply poorly designed. The FDICs returning of the premium to banks when itsfund is well-capitalised would be akin to a life-insurer not charging a premium because it is well-capitalised and theinsured has lived longer than the actuarial tables would imply!Further, the returning of the premium makes the FDIC funds balance highly pro -cyclical, in that the fund is neverwell-prepared for a reasonable systemic crisis and it must raise the premium when crises occur rather than in goodtimes when banks would find it easier to pay. Further, the scheme is divorced from any incentive considerations.The rationale for charging banks a premium on a continual basis based on individual and systemic risk regardless ofthe deposit insurance fund's size is that it causes banks to internalise in good times the costs of their risks (andresulting future failures) on the fund and rest of the economy. Since a systemic crisis would most likely cause thefund to fall short and dip into taxpayer funds, the incentive-efficient use of excess fund reserves is as return totaxpayers rather than to insured banks.

Its time to measure and quantify systemic risk

While the nature of our three prescriptions for the efficient design of premium schemes is straightforward, inpractice, quantifying systemic risk can be a challenge. However, it is time now for academics, practitioners, andpolicy-makers to rise to this challenge. A recent advance in Acharya, Pedersen, Philippon, and Richardson (2009)provides a measure of systemic risk that would be suitable for revisions to future deposit insurance schemes.

References

Acharya, Viral (2009) A Theory of Systemic Risk and Design of Prudential Bank Regulation , forthcoming, Journal ofFinancial Stability.

Acharya, Viral, Lasse Pedersen, Thomas Philippon and Matthew Richardson (2009) Regulating Systemic Risk,Chapter 13 in Restoring Financial Stability: How to Repair a Failed System, eds. Viral Acharya and MatthewRichardson, John Wiley & Sons.Acharya, Viral and Tanju Yorulmazer (2007) Too-Many-To-Fail -- An Analysis of Time-inconsistency in Bank ClosurePolicies, Journal of Financial Intermediation, 16(1), 1-31.Acharya, Viral and Tanju Yorulmazer (2008) Cash-in-the-Market Pricing and Optimal Resolution of Bank Failures ,Review of Financial Studies, 21, 2705-2742.Cooley, Thomas (2009) A Captive FDIC Forbes, 15 April.Hoggarth, Glenn, Jack Reidhill and Peter Sinclair (2004) On the Resolution of Banking Crises: Theory and Evidence,Working Paper #229, Bank of England.Mailath, George and Loretta Mester (1994) A Positive Analysis of Bank Closure, Journal of Financial Intermediation,3, 272-299.Masciandaro , Donato and Marc Quintyn (2009). Financial regulation: Assessing the Obama administrations financialsupervision white paper, VoxEU.org, 1 August 2009.Pennacchi, George (2009) Deposit Insurance, Paper prepared for AEI Conference on Private Markets and PublicInsurance Programs.

Saunders, Anthony and Marcia Millon Cornett (2007) Financial Institutions Management: A Risk ManagementApproach, Irwin/McGraw-Hill.Shleifer, Andrei, and Robert Vishny (1992) Liquidation values and debt capacity: A market equilibrium approach, Journalof Finance, 47: 1343-1366.

1 For example, Hoggarth, Reidhill and Sinclair (2004) study resolution policies adopted in 33 banking crises over theworld during 1977-2002. They document that when faced with individual bank failures, authorities have usuallysought a private sector resolution where the losses have been passed onto existing shareholders, managers, andsometimes uninsured creditors but not to taxpayers. However, government involvement has been an importantfeature of the resolution process during systemic crises at early stages, liquidity support from central banks andblanket government guarantees have been granted, usually at a cost to the budget; bank liquidations have beenvery rare and creditors have rarely made losses.

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A Radical Solution for America's Insolvent Financial System

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A Radical Solution for America's Insolvent Financial System

The core problem of the United States' banking system (and maybe the world's banking system) is not

liquidity but insolvency. The liabilities of the United States' banking system exceed the value of its

assets. The issue is not only the toxic assets (toxic mortgage backed securities, toxic commercial real

estate loans, sub-prime mortgages, alt-A loans, adjustable loans likely to go bust, increase in prime

mortgage default rates, etc) but also off-balance sheet liabilities (such as expected huge unaccounted

for future derivatives losses).

This means that bailouts are just beginning and will require bigger and bigger sums of taxpayer money

as time goes on. The government will resort to borrowing more and more and eventually to printing

money when treasury debt auctions start failing. The end result of this path is a currency collapse and

probably total chaos as expected by gold bugs.

One other way to deal with this issue is to stop the bailouts and let the dominoes fall. Defaults and

cross-defaults will cause many, many depository institutions (even very large ones) to collapse leading

to extreme decrease in money supply as bank deposits are destroyed. Deposits of failed banks cannot be

used to pay bills, make purchases and/or service debts.

Which will probably lead to even more defaults as unemployment increases and debtor's are unable to

service their debts. This process will probably cause extreme deflation as businesses lower prices in a bid

to survive. This will also lead to wage cuts, increased unemployment and a deflation spiral and much

chaos. But probably less chaos than a currency collapse.

Is there a better way?

Here is my idea:

1) We essentially need an orderly bankruptcy and liquidation of the United States' financial system.

2) I suggest we create a government owned bank and transfer all deposits of the private commercial

banking system to the new government owned bank. This "transfer" is really just new money creation.

This new money will be digital cash (electronic version of physical paper cash). Very much like reserves

at the FED.

3) Note that the plan will not create net new money since we will be destroying all deposits of the

commercial banking system in the process.

4) All assets of the commercial banking system will be transferred to the government and auctioned off

in an orderly manner over the next 10 years. The proceeds from the sale would go the United States

treasury and not the commercial banks. The assumption here is that commercial banks deserve nothing

since the entire industry would have been most likely destroyed any way. Even good banks would have

been destroyed due to bank runs and defaults if the government had allowed the dominoes to fall. Of

course bank shareholders, bank bond holders and counter parties of bank derivatives would not receive

anything.

5) After the transfer FDIC protection will be removed for any private bank which wishes to remain in

business or any new private depository institution or bank. From that point on the government should

make it absolutely clear that there will be no more bailouts and no more conversions. This will


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discourage (but not completely eliminate) fractional reserve deposit banking and private money creation

that results from pyramiding of government created money. This will also limit debasement of the

currency that results from fractional reserve deposit banking. In fact, we can have "free banking" from

that point on and not even have reserve requirements or capital requirements. All depositors who use

private banks will be fully at-risk. The industry will have to set the interest rate high enough to attract

depositors.

6) The new government bank will act as an electronic "piggy bank" only. All deposits will be 100%

reserve and it will not make any loans. Loan making will be left to the private banking system (with no

deposit insurance or a possibility of a future bailout). The new government owned bank exists only as a

"safe" money storage and a payment clearing system so the public does not have to carry around

physical paper cash to make purchases and pay bills.

7) Of course this plan is not without pain or cost. Cost of funds for banks and borrowers will probably

rise as bank deposits are a source of very low cost money for the banks. Nothing is free. We are just

exchanging higher cost of funds for removal of systemic failure risk. Economically we are recognizing

that when money is loaned there is always credit risk.

8) We are just separating the payment and clearing transaction system which is absolutely necessary for

day-to-day commerce (no credit risk) from the loan banking and investment system (has credit risk).

Mansoor H. Khan

http://aquinums-razor.blogspot.com/
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Systemic Risk and Deposit Insurance Premiums

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